REPORT Pandemic EBT Implementation Documentation Project
REPORTPandemic EBTImplementationDocumentation ProjectPREPARED FORCenter on Budget and Policy PrioritiesFood Research & Action CenterSeptember 2020GROWING IDE AS INTO SUCCESS koneconsulting.com
Table of ContentsExecutive Summary . 5Introduction . 7Background. 8Study Objectives . 9Approach/Methodology . 10Rapid Assessment. 10Nationwide Survey . 10In-depth Interviews for Eight Selected States . 11P-EBT Participant Interviews . 12Overview of P-EBT Implementation . 13Variations in Eligibility . 17Pre-K and Head Start in Participating Schools . 17Newly Eligible Children . 17Approaches to Implementing P-EBT . 21Getting to Implementation . 21Availability of Student Data . 21Implementation Models . 23Direct Issuance for SNAP; Applications for All Others . 25Direct Issuance for SNAP and Other Program Participants; Applications for All Others . 25Direct Issuance to All but a Subset and/or Used a Back-up Application . 25Direct Issuance for All. 26Experience with an Application or Information Collection Form . 28Application Methods Available to Families . 30Disseminating the Application. 32Ease and Effectiveness of Implementation Models . 35Implementation Phases . 37Eligibility Confirmation . 39Issuing Benefits . 40Eligibility System . 40Costs . 41Issuing P-EBT Cards to the Child or Head of Household . 42Benefit Card Appearance . 44EBT Vendors . 45koneconsulting.com2
Benefit Card Activation . 45Single vs. Multiple Benefit Issuances . 49Communication and Troubleshooting with Families . 50Communication with the Public . 50Communication through Schools . 51Communication Directly with Families . 52Targeted Outreach . 54Responding to Family Inquiries . 57Reasons for Inquiries . 59Inquiry Backlogs . 59Troubleshooting . 60Staffing . 61Outcome Tracking. 63Lessons Learned . 64Areas for Further Inquiry . 68Appendices . 70Appendix A – Glossary . 70Appendix B - Survey . 72koneconsulting.com3
AcknowledgmentsKoné Consulting would like to thank: the Center on Budget and Policy Priorities and the Food Researchand Action Center for working tirelessly to reduce food insecurity and hunger in this country, and forinviting us to assist them with this study; USDA Food & Nutrition Service for making Pandemic-EBTpossible; and, all of the state officials and school districts personnel in the 52 states and territories whoagreed to be interviewed, those who responded to the survey, and all who worked tirelessly over the pastsix months to implement P-EBT during these unprecedented times in order to reduce hunger and foodinsecurity in their communities. We would also like to thank American Public Human Services Association,Brookings Institute, the Center for Law and Social Policy, Code for America, the Council of Chief StateSchool Officers, the Education Trust, Hunger Task Force, the Leadership Conference on Civil and HumanRights, the National Association for the Advancement of Colored People, New America, Propel, Share OurStrength, and the Urban Institute for sharing their perspectives or reviewing study materials. This studywas conducted expediently to make the information gathered available to policymakers, state officials,and school district personnel who continue to grapple with delivering services to children virtually in the2020-2021 school year. In a few places in this report we have highlighted areas that are ripe for furtherstudy once administrative data on outcomes is more widely available.Koné Consulting would also like to thank Rachel Cahill of Cahill Consulting for her efforts in bringing thisreport to life. Rachel is an advocate for individuals and families in need and works tirelessly to addresshunger across our country. Rachel has been instrumental in implementing the Pandemic-EBT program inher home state of Ohio. We were fortunate to have Rachel on our team.koneconsulting.com4
Executive SummaryThe Pandemic EBT program (P-EBT) played a critical role in helping to fill significant holes in families’ foodbudgets that emerged when schools closed, and jobs disappeared at the outset of the COVID-19pandemic. P-EBT provided 250 to 450 per child, depending on the state’s federal school mealreimbursement rate1 and the average number of days schools were closed in their state in the spring of2020. Nationwide, P-EBT during the spring of 2020 had the potential to deliver up to 10 billion in foodbenefits to up to 30 million low-income school children.The Center on Budget and Policy Priorities (CBPP) and the Food Research & Action Center (FRAC)commissioned this report to document the development and implementation of states' Pandemic EBTprograms for the 2019-2020 school year. The purpose of this rapid study was to document differentapproaches that states took to implement Pandemic EBT and lessons they learned along the way.At the outset of this documentation project, it was notclear whether most, let alone nearly all, eligible statesand territories including the District of Columbia andVirgin Islands, would ultimately implement P-EBT.2Yet, on August 13 the last state was approved toimplement P-EBT before the September 30 deadline.The fact that 52 states and territories managed to implement a brand-new benefit for millions of childrenin less than 5 months with minimal federal guidance is an incredible feat by state agencies, speaks to theircommitment to meeting the needs of low-income children, and is a testament to the importance ofenhanced federal nutrition assistance during an ongoing public health and economic crisis. In this report"states" will include the states, the District of Columbia, and the Virgin Islands.The structure and rapid roll-out of P-EBTpresented many challenges for statesbut there are early lessons learned fromthe successes, and improvements thatcan be made based on the shortcomingsof the first implementation of the1AK, HI, and USVI have higher reimbursement rates.The Northern Mariana Islands and American Samoa were not eligible. Guam did not opt to participate in P-EBT. Puerto Ricowas not eligible for P-EBT even though it participates in the National School Lunch Program on the same basis as U.S. states,because SNAP operates as a block grant in Puerto Rico.2koneconsulting.com5
program. It appears the major driver for state decisions about implementation was the availability ofstudent data and the associated challenges of interfacing with SNAP EBT systems. Direct issuance tochildren was the model that appears to have worked best, and yet for a majority of states thecomprehensive student data needed to issue benefits did not exist in one place and had to be laboriouslygathered up. This might be one reason not every state was able to issue P-EBT benefits to children whosefamilies became newly eligible for F/RP meals because of job loss related to the pandemic.As of the writing of this report, Congress has extended P-EBT for the 2020-21 school year, but noguidance has been issued by the U.S. Department of Agriculture's Food and Nutrition Service (FNS). Thereis also a possibility that a program like P-EBT will need to be implemented again in the future. For thesereasons this study has been rapidly conducted so lessons learned can be gleaned for the secondimplementation. The following lessons learned were gleaned from the analysis of the data gathered forthis study and our own knowledge of the program and states. A fuller discussion of the lessons can befound later in the report.Lesson 1: The P-EBT program worked to provide food assistance to millions of school-aged childrenduring a crisis, and it took impassioned and dedicated federal, state, and local staff to make it happen.Lesson 2: Direct issuance to children was the model that worked best based on early reports.Lesson 3: States need resources3 to improve the reliability of student data (how frequently it is updated)and interoperability of F/RP meals data and student enrollment data with their SNAP systems4.Lesson 4: Troubleshooting benefit issuance was required for some children in every implementationapproach- direct issuance, application, or a hybrid.Lesson 5: It was important to enhance collaboration and communication amongst the P-EBT partners instate agencies, advocacy organizations, and with families.3The federal government typically provides administrative funding for child nutrition programs, including the NSLP, which PEBT was designed to replace, yet P-EBT requires states to provide a 50/50 match like in the SNAP program.4The requirement to match NSLP data with SNAP data added to the complexity of implementation and the likelihood thateligible children were missed. This requirement was intended to exclude a small number of children who are home-schooled orin a private school not participating in NSLP.koneconsulting.com6
IntroductionWhen schools unexpectedly shut their doors at the outset of the COVID-19 pandemic in March 2020,elected leaders recognized the consequences for low-income school children who were missing out on,among other things, nutritious meals at school. One of several responses that Congress established toaddress this issue through the Families First Coronavirus Response Act (FFCRA) was Pandemic EBT (PEBT). P-EBT is a brand-new benefit program meant to give states a way to provide food assistance tochildren approved for free or reduced-priced (F/RP) school breakfasts and lunches to compensate for themeals they missed at school during the spring of 2020.P-EBT was created to provide families of children eligible for F/RP meals with a grocery debit card toreplace the missed meals. School districts worked valiantly to provide grab-and-go meals, but picking upseveral days of prepared meals might not have been feasible for working parents, or families living in ruralareas or otherwise a long distance from the school pickup site, and might not be advisable for those athigher health risk.P-EBT cards operated with the same Electronic Benefits Transfer (EBT) technology used for SupplementalNutrition Assistance Program (SNAP) benefits. As a result, they allowed families to use benefits in thecourse of their ordinary shopping at any SNAP-authorized retailer.State SNAP and Child Nutrition agencies were charged with developing and executing the P-EBT programfrom scratch as quickly as possible; an opportunity and challenge they rose to at a time theysimultaneously faced numerous other challenges and demands, including significant increases in SNAPapplications and other programs administered by the same agency and staff, such as unemploymentinsurance.Since March 2020, states havebeen working tirelessly to issueP-EBT benefits to all eligiblechildren. States had to use theirbest judgement to design andexecute P-EBT under extremelydifficult circumstances withlimited and evolving guidance from FNS, whose staff were also operating with limited direction fromCongress and under challenging circumstances because of the pandemic. Such an undertaking requiredfederal and state officials and school district personnel to work long days and weekends and use theircreativity and agility to help ensure children in the communities they serve had access to food they weremissing out on because they weren't going to school.koneconsulting.com7
BackgroundP-EBT was authorized by the FFCRA on March 18, 2020. FNS issued two pieces of publicly availableguidance for states - a Guidance Memo on March 20, 2020 and a Question and Answer documentpublished on April 15.5 In order to implement P-EBT, states had to submit an implementation plan to FNSfor approval, which had to be signed by state officials from both the SNAP and Child Nutrition agencies.States were required to include both SNAP and non-SNAP households in their implementation plan andcommit to conducting a public information campaign about the availability of P-EBT. Other state planelements required by FNS included:1. How the state would confirm P-EBT eligibility with school enrollment data;2. How benefit allotments would be calculated;3. How benefits would be distributed to SNAP and non-SNAP households.In the April 15 guidance, FNS communicated that states would be required to support 50% of theadministrative costs to implement P-EBT choosing to apply SNAP's standard 50/50 reimbursement rate.Figure 1: FNS approval dates for each state, listed in sequential order of approval by row.FNS approved the first state P-EBT plan on April 9 for Michigan, followed by Rhode Island on April 10.Another six states - North Carolina (4/16), Arizona (4/17), Illinois (4/17), Massachusetts (4/17), Alabama(4/21), Wisconsin (4/22) were approved in the week following FNS' April 15 guidance. FNS approved anadditional nine states by April 30 - California (4/23), Connecticut (4/24), Kansas (4/25), Virginia (4/25),Maryland (4/28), New Mexico (4/28), Oregon (4/29), Delaware (4/30), West Virginia (4/30). Of theremaining states, FNS approved P-EBT plans for 22 states in May, 10 states in June, two states (Nevada5Both can be found at avirus-pandemic-ebt-pebt and are included in theResource Library associated with this report.koneconsulting.com8
and Utah) in July, and one state (Idaho) in August. (See Table 2 for every state's plan approval date.) Thatmore than half the states had plans approved within six weeks is indicative of how quickly states and FNShad to react to the March 18th authorization. FNS provided relatively little guidance and focused onworking with individual states on plan approval through email exchanges and phone conversations. Onlythree states began issuing P-EBT benefits in April (Michigan, Rhode Island, and Illinois) with all otherissuances occurring in May and beyond.Study ObjectivesCBPP and FRAC conducted this study to rapidly document the development and implementation of P-EBTwhile it was still underway and state impressions were fresh. The goals of the project were to buildcollective understanding of the different approaches that states took to implement P-EBT in the springand summer of 2020, draw out lessons learned in time to inform federal and state decisions related to PEBT for the 2020-2021 school year, and inform future efforts to deliver benefits to families with childre
commissioned this report to document the development and implementation of states' Pandemic EBT programs for the 2019-2020 school year. The purpose of this rapid study was to document different approaches that states took to implement Pandemic EBT and lessons they learned along the way. At the outset of this documentation project, it was not
utumie Fomu ya Maswali ya P-EBT. 14. Je, kiasi cha pesa cha manufaa ya P-EBT kiliamuliwa vipi? Utoaji wa P-EBT Vigezo P-EBT 1 - Majira ya Kuchipua 2020 Kiasi cha pesa kilichowekwa kwa siku ambacho wanafunzi wangekuwa wamepokea milo ya bila malipo au iliyopunguzwa bei, ikiwa si kwa ajili ya dharura ya afya ya umma. P-EBT 2 - Majira ya
meals if they have P-EBT benefits. P-EBT is a program by COSS and COE, funded by the USDA, an equal opportunity provider and employer. Pandemic EBT Get help buying food while schools are closed Families can receive up to 365 per child to spend on groceries in addition to pick up meals from school through a new program called Pandemic EBT or P-EBT.
A: Yes. Anyone who has received P-EBT in the past will receive a new P-EBT card. All remaining issuances will go . on the P-EBT card received with the April 15, 2021, issuance. If they are determined eligible after the first issuance, a new P-EBT card will be mailed with the initial issuance and then ongo
At least 3.8M children (childcare and school-aged) received SY20 -21 P-EBT benefits either directly on existing SNAP cards or new P-EBT cards through the P -EBT online application. They were SNAP certified before 6/30. For summer '21 P-EBT benefits, children verified to be enrolled in an NSLP participating
recurrent assessment and training within an approved EBT program. EBT module. A session or combination of sessions in a qualified FSTD as part of the 3-year cycle of recurrent assessment and training. EBT session. A single defined period of training in a qualified FSTD that normally forms part of an EBT module. EBT scenario.
CALIFORNIA-DSS-MANUAL-EBT MANUAL LETTER NO. EBT-03- 01 Effective 2/13/03 Page 7 (2) Batch Interface – An interface between a county eligibility system and the EBT system. Various records, wrapped in a batch header and trailer, are transmitted from the eligibility system processor to the EBT system at a minimum of daily and possibly more often.
The Pandemic EBT (P-EBT) program in New York served over 2.4 million children by distributing more than 1 billion in benefits between May and September 2020. New York is the largest state to directly issue P-EBT benefits to families. The sheer size of the program slowed implementation, as did data challenges. Nonetheless, state leadership
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